United States v. William Hines
885 F.3d 919
6th Cir.2018Background
- December 15, 2015: Detective Daniel Evans swore out an affidavit to search 668 Eastlawn (home owned by Hines’s mother) for drugs after tips and surveillance.
- Two unnamed confidential sources (CS1, CS2) told police: CS1 saw heroin at the residence on Dec. 14; CS2 had previously received heroin from Hines at 668 Eastlawn and said Hines arranged a Dec. 15 meeting regarding a heroin shipment.
- Surveillance corroborated that Hines regularly came and went from 668 Eastlawn and that on Dec. 14 he left the house and drove to the club CS2 identified. Officers also noted Hines’s prior DEA history (wire interceptions, prior large seizures).
- Judge Chauvin issued the warrant; police executed it Dec. 15 and seized multi-pound quantities of cocaine and heroin, cash, and drug paraphernalia.
- Hines moved to suppress arguing (1) the affidavit lacked probable cause—informants were anonymous and unproven reliable—and (2) the good-faith exception did not apply. The district court granted suppression.
- Sixth Circuit reversed: held the affidavit, read in totality, established probable cause; alternatively, officers acted in objectively reasonable reliance on the warrant (Leon good-faith exception).
Issues
| Issue | Plaintiff's Argument (Hines) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Whether the affidavit established probable cause to search 668 Eastlawn | Affidavit failed to show informants’ reliability (generic “reliable” labels), no substantial independent corroboration tying drugs to the residence | Informants’ bases of knowledge (CS1 saw heroin; CS2 had repeatedly received heroin at the address and described a shipment/meeting) plus surveillance and defendant’s trafficking history suffice under totality-of-circumstances | Reversed: affidavit established probable cause when considered in totality |
| Whether independent police corroboration was required and sufficient | Corroboration was minimal (only that Hines went to the nightclub) and insignificant | Corroboration of nonobvious details (travel to the club as predicted), surveillance of regular comings/ goings, and prior DEA information provided adequate independent corroboration | Reversed: corroboration and prior investigative facts supported probable cause |
| Whether the affidavit was a “bare-bones” affidavit precluding good-faith reliance | Affidavit so conclusory that a reasonably well-trained officer should not rely on it; affiant executed the search so reliance was unreasonable | Affidavit supplied concrete facts (recent sightings, past drug transactions, specified meeting) — not bare-bones; prior precedent allows good-faith even if affiant executes warrant | Reversed alternative: good-faith exception applies; officers reasonably relied on the warrant |
| Whether suppression is appropriate despite judicial issuance of warrant | Judicial issuance insufficient where affidavit lacked indicia of reliability; suppression needed to deter improper police reliance | Exclusionary rule should not bar evidence where no police misconduct and reliance on warrant was objectively reasonable | Reversed: exclusionary rule inapplicable under Leon/its progeny; remand for further proceedings |
Key Cases Cited
- Illinois v. Gates, 462 U.S. 213 (1983) (announces totality-of-the-circumstances test for informant-based probable cause)
- United States v. Leon, 468 U.S. 897 (1984) (establishes good-faith exception to the exclusionary rule)
- United States v. Dyer, 580 F.3d 386 (6th Cir. 2009) (probable cause requires fair probability evidence will be found; review four-corners of affidavit)
- United States v. Moore, 661 F.3d 309 (6th Cir. 2011) (upheld warrant where informant’s basis of knowledge tied crimes to the address)
- United States v. White, 874 F.3d 490 (6th Cir. 2017) (discusses bare-bones standard and objective reasonableness for good-faith reliance)
- United States v. Carpenter, 360 F.3d 591 (6th Cir. 2004) (applies Leon good-faith exception where affidavit included sufficient nexus between residence and crime)